Pesky IFA has been at it again. Client wants to transfer company asset to himself. Company has nominal share capital but is of significant value.
IFA has come up with wheeze - new holding company formed by share-for-share, with significant share capital/premium. Asset transferred intra-group and then out to client as a capital reduction with CGT at 10%
To be fair, it looks good on paper (and might even have worked in years gone by) but I intend to tell client that it won’t because (a) HMRC are unlikely to give clearance on the share-for-share and (b) even if we could come up with a convincing story for (a) the strategy is right in the middle of Transactions in Securities.